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In the ongoing property exemption battle between Pittsburgh and UPMC, UPMC has moved again for dismissal of the case, noting that it has no employees and therefore cannot be liable for payroll taxes.

While probably technically correct, the more interesting fact from my perspective is that UPMC is a holding company shell at the top of a business enterprise consisting of 44 subsidiaries.

Yes, 44.

Think about that for a second. We have a supposedly charitable enterprise that has 44 separate business entities (not all of them tax-exempt). This kind of structure is not unusual for large healthcare enterprises, and is even becoming more common for large universities.

Somehow, I don't think this is exactly what the English Parliament had in mind when it passed the Elizabethan Statute of Charitable Uses in 1601.